Statutory tenancy protection is personal; heirs cannot claim bona fide requirement defence or seek remand after valid termination.

After termination of the contractual tenancy, the occupant remained only a statutory tenant with a personal protection to continue in possession, not an estate or transferable interest. That protection did not devolve on death unless the rent control statute expressly so provided, so the heirs could defend only in the deceased tenant's representative character and not assert a personal defence unavailable to him. The landlord's bona fide requirement was treated as such a personal ground, and the Court held that the legal representatives could not resist eviction on that basis. The Court also held that the contractual tenancy had been duly terminated by notice, so there was no basis for remand on that issue.

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Issues: Whether the heirs and legal representatives of a deceased statutory tenant could claim the protection of the rent control statute and resist eviction on the ground that the landlord had not established bona fide and reasonable requirement, and whether the case required remand on the question of termination of tenancy.

Analysis: After termination of the contractual tenancy, the tenant remained only a statutory tenant with a personal statutory protection to continue in possession. That protection was not an estate or transferable interest and did not devolve as tenancy rights upon death unless the statute so provided. The legal representatives could defend the appeal in their representative character and urge contentions available to the deceased, but not a ground which was personal to the deceased statutory tenant. The ground of the landlord's bona fide requirement was such a personal protection. The Court also found that the contractual tenancy had been duly terminated by notice, and there was no basis to remand the matter for re-determination of that point.

Conclusion: The heirs of the deceased statutory tenant could not claim tenant-status in their own right or invoke the personal protection against eviction based on bona fide requirement, and the plea for remand failed.

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